Access and place improvements: The Grand Parade – Kyeemagh to Sans Souci

General Holmes Drive General Holmes Drive. Rendering by Transport for New South Wales

[A submission I made personally to the Bayside Council, but it might be of general interest]

When asked to “Have Your Say” on “Access and place improvements: The Grand Parade – Kyeemagh to Sans Souci”, input is requested based on the proposed changes without any evidence provided about the justification for, or consequences of the changes.   

Ethical engineering requires such evidence be used before making an informed recommendation. For instance, Engineers Australia, the peak body of the engineering profession, has a Code of Ethics, item 2.3 says:

 “Act on the basis of adequate knowledge “ 

In this case, “adequate knowledge” for the recommendation of adding capacity, in the form of an expanded clearway and changes to roads on the Grand Parade would involve the conduct of what is usually referred to as a “Traffic Study”. A “Traffic Study” collects data on existing conditions (motor vehicle flows, freight traffic, pedestrian flows, transit usage, parking, air quality, crash risks, network conditions, etc.) on the relevant network — the link(s) being considered, as well as those upstream and downstream, and those which might serve as alternatives.

 It then tests alternative interventions in the network and assesses them against appropriate performance indicators. These performance indicators include change in travel demand patterns (induced demand resulting from shorter travel times), traffic congestion, safety, pedestrian delay, transit walk times, air quality, and so on. This is often conducted using tools like microscopic traffic simulators and strategic transport models, among others, combined with engineering judgment and experience. 

If an intervention unambiguously improves all performance indicators, it is an easy recommendation. If an intervention improves some indicators, and not others, a recommendation may be made, but the advantages and disadvantages are presented and reported to policy makers. 

One hopes a high-quality traffic study took place, but the evidence thereof is missing.  What is presented to the public is a “hypothesis” that this is an “improvement”, something that should be tested, but for which there is to date no evidence. Sometimes interventions are experiments or trials because evidence needs to be gathered from the real world, and models can only do so much. Engineering practice would require labelling those trials as such, and they would have a definite start and end time, at which time an evaluation would be conducted, and a decision made.

However, in this case, the proposal is presented as a fait accompli, not a trial. The consequences of the proposed interventions are not available to the public, or I understand, elected officials.

Item 3.3 of the Engineers Australia Code of Ethics says:

“Make reasonable efforts to communicate honestly and effectively to all stakeholders, taking into account the reliance of others on engineering expertise “

Where is the evidence that was undertaken? The traffic study must be made public to allow for peer and expert review. Good public policy requires all information be made available to the public and policy makers, so that the trade-offs of alternatives can be openly discussed and weighed.

Item 4.2 of the Code of Ethics says:

 “Practise engineering to foster the health, safety and wellbeing of the community and the environment” 

In this case, that means the changes in air quality and CO2 emissions associated with the proposed changes need to be reported. Without a traffic study, we cannot know whether the proposed “improvement” worsens emissions because of the higher speeds and increased traffic flow that will be accommodated.

I encourage the Bayside Council to demand the Traffic Study for the proposed changes be made public and subject to peer review before any such intervention is approved. If no Traffic Study was conducted, the proposal should be rejected.